Justia Wyoming Supreme Court Opinion Summaries

The Wyoming Workers' Compensation Division denied Rick Bodily benefits for medical expenses related to his micro-lumbar discectomy for a herniated disc in his lower back after determining that Bodily's medical treatment was not related to his compensable work-related back injuries. The Office of Administrative Hearings (OAH) granted the Division's motion for summary judgment against Bodily. The district court affirmed. The Supreme Court reversed OAH's summary judgment, holding (1) genuine issues of material fact about causation of Bodily's disc herniation existed; and (2) the OAH erroneously acted as the trier of fact at the summary judgment stage in this case by weighing all the evidence and making credibility determinations. View "Bodily v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Celeste Grynberg and her husband were co-owners of Grynberg Petroleum. Celeste filed a complaint for declaratory relief, breach of contract, unjust enrichment, and conversion against L&R Exploration Venture and numerous individuals and entities having an interest in the venture (collectively L&R), claiming that L&R owed her compensation for services Grynberg Petroleum provided to L&R and that she was entitled to payment of those amounts. The district court granted summary judgment for L&R and dismissed the complaint on the basis of res judicata, finding that Celeste was in privity with parties involved in prior litigation in Colorado and New York and her complaint involved the same subject matter and issues resolved in those proceedings. The Supreme Court affirmed, holding that Celeste was in privity with her husband, who was a party in the New York proceedings, as the assignee of his interest in L&R and with Grynberg Petroleum as the co-owner of the company and was bound by the prior rulings. View "Grynberg v. L&R Exploration Venture" on Justia Law

Shannon Cave suffered a work-related injury and was awarded temporary total disability (TTD) benefits during her recovery. After Cave rejected an offer of temporary light duty work from her employer, the Wyoming Workers' Safety and Compensation Division (Division) reduced Cave's TTD benefits to one-third of the previously authorized amount in accordance with Wyo. Stat. Ann. 27-14-404(j). The Office of Administrative Hearings (OAH) upheld the reduction of TTD benefits. The district court reversed the OAH decision. The Supreme Court reversed the district court's order, holding that the OAH decision was supported by substantial evidence and was not contrary to law as the hearing examiner properly determined that the offer of light duty employment tendered to Cave was bona fide, and therefore, the OAH was obligated to reduce Cave's TTD benefits. View "State ex rel. Wyo. Workers' Safety & Comp. Div. v. Cave" on Justia Law

Francis Weber was severely burned by hot mineral water when he lost consciousness in a steam room in Hot Spring State Park. Weber brought a personal injury action against several defendants, including the State. The district court granted summary judgment in favor of the State, concluding that it was immune from suit pursuant to the Wyoming Governmental Claims Act. The Supreme Court reversed, holding that the State's activities in the park fell within the statutory waiver of immunity for operation and maintenance of a public park as (1) overseeing building construction on leased property and delivery of hot mineral water to lessees are part of the State's operation of the park, and (2) under these circumstances, the State's operation and maintenance of the park included overseeing and/or inspecting its lessee's property. Remanded. View "Weber v. State" on Justia Law

Steve Glen filed suit against his employer, Union Pacific Railroad, claiming that a work-related injury was caused by Union Pacific's negligence. Previously, the Supreme Court reversed a grant of summary judgment in favor of Union Pacific after finding the railroad had a duty to exercise ordinary and reasonable care in the operation of its railway. After remand, the jury determined that both parties, as well as two non-party actors, were negligent and awarded damages to Glenn. The Supreme Court reversed the district court, holding that the district court erred in refusing to admit evidence of a prior incident involving Union Pacific that was the catalyst for a change in the railway's safety procedures and that the error was prejudicial to Glenn. Remanded for a new trial. View "Glenn v. Union Pac. R.R. Co." on Justia Law

Appellants were the personal representatives of the estates of a husband and wife who were killed in a car accident. The accident was caused by a driver who, prior to the accident, had become intoxicated as a result of consuming alcoholic beverages at a bar and a saloon in Wyoming. Appellants filed a wrongful death and negligence complaint against the owners of the bar and saloon. Appellants also sought a judgment declaring Wyo. Stat. 12-8-301, which provides that no person who legally provides alcohol to another person is liable for damages caused by the intoxication of the other person, was unconstitutional if, as a matter of law, the statute provided immunity to Appellees for their conduct. The district court granted Appellees' motion to dismiss on the ground that the Supreme Court had already found the statute to be constitutional. The Supreme Court affirmed, holding that (1) in the statute, the word "legally" in the phrase "legally provided" does not encompass municipal ordinances, and (2) the statute violates neither the constitutional doctrine of equal protection nor the constitutional prohibition of special laws. View "Baessler v. Freier" on Justia Law

Employee injured his knee while climbing into his employer-provided truck as he was preparing to leave on a work-related trip. The Wyoming Workers' Safety and Compensation Division (Division) denied Employee's requested workers' compensation benefits related to his injury. The Office of Administrative Hearings (OAH) granted summary judgment in favor of the Division. The district court affirmed the OAH's decision. At issue on appeal was whether Employee's injury was sustained while he was being transported by a vehicle of the employer as the statute requires. The Supreme Court affirmed, holding (1) the statute plainly and unambiguously requires that for an injury sustained during travel to be compensable, it must occur as the employer's vehicle is carrying the employee from one place to another; and (2) because Employee here was entering the vehicle in preparation for that transportation when he was injured, the injury he sustained was not compensable. View "Barlow v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Carol Middlemass suffered a broken right shoulder in 1987 as a result of a car accident. Middlemass recovered and was able to use her shoulder normally. In 2009, Middlemass stated that she injured her right shoulder while working for Y-Tex Corporation. The Wyoming Workers' Safety and Compensation Division denied Middlemass's request for worker's compensation benefits for the injury due to her preexisting condition. The Office of Administrative Hearings (OAH) upheld the Division's denial, and the district court affirmed. On appeal, the Supreme Court affirmed, holding (1) the OAH hearing examiner's conclusion that Middlemass did not meet her burden of proving that her shoulder injury was caused by her work activities was supported by substantial evidence; and (2) the OAH hearing examiner properly ruled that expert medical testimony was required to establish that Middlemass' work activities caused the injury. View "Middlemass v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant Dawn Schossow injured her back while working as a nurse. Upon returning to work, Appellant requested permanent partial disability (PPD) benefits pursuant to Wyo. Stat. Ann. 27-14-405(h), which governs the availability of PPD benefits and sets out the elements an injured worker must prove to qualify to receive the benefits. Appellant's request was denied. The Office of Administrative Hearings (OAH) upheld the denial of benefits, and the district court affirmed the OAH's decision. On appeal, Appellant contended that the OAH hearing examiner erred as a matter of law in interpreting section 27-14-405(h)(i) and that the hearing examiner's decision was not supported by substantial evidence. The Supreme Court affirmed, holding (1) the hearing examiner properly applied the statute in assessing what wage to use when determining Appellant's PPD eligibility; and (2) the hearing examiner's conclusion that Appellant was capable of earning ninety-five percent of her pre-injury wage, and thus was not eligible for PPD benefits, was supported by substantial evidence. View "Schossow v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Kara Dunham filed a lawsuit against Robert Fullerton for injuries stemming from an automobile accident. After filing his answer, Fullerton passed away. Fullerton's counsel then made a Wyo. R. Civ. P. 68 offer of settlement, and Dunham filed a notice of acceptance pursuant to Rule 68. Fullerton's counsel filed the acceptance along with the offer of settlement. The district court dismissed the action without prejudice, ruling that Dunham's acceptance was invalid because Dunham attempted to reserve the right to litigate all issues in an action against the estate. On appeal, the Supreme Court affirmed, holding that (1) the district court correctly recognized the legal requirement that a Rule 68 acceptance must mirror the offer, and (2) the district court did not err in refusing to enter judgment upon Dunham's acceptance of a Rule 68 offer of settlement. View "Dunham v. Fullerton" on Justia Law